Data privacy has become a critical concern for both consumers and businesses. As public scrutiny increases, governments around the world have introduced legal frameworks to promote responsible use of technology, especially when it comes to collecting, storing, and selling personal data.
Two of the most prominent examples are the California Consumer Privacy Act (CCPA) and the European Union’s General Data Protection Regulation (GDPR). Both establish strict rules regarding how personal information is handled and grant individuals greater control over their data. However, they differ in several critical areas, including scope, enforcement, and compliance obligations.
In this article, we’ll discuss:
- What the CCPA is
- What the GDPR is
- The key similarities and differences between the two
- Whether your organization should comply with both regulations
What is the California Consumer Privacy Act (CCPA)?
The California Consumer Privacy Act (CCPA), enacted in 2018, is a landmark state legislation designed to enhance data privacy protections and give California consumers greater control over their personal information. It grants individuals several rights, including:
- The right to know about the personal information a business collects about them, how it’s used, and how it’s shared
- The right to delete personal information collected about them (with some exceptions)
- The right to opt out of the sale of personal information
- The right to non-discrimination for exercising their CCPA rights
Under the CCPA, personal information is broadly defined as any data that identifies, relates to, or could be reasonably linked to an individual or household in California. This includes names or nicknames, email addresses, IP addresses, purchase histories, and sensitive personal information.
The CCPA applies to all for-profit businesses that operate within California, collect data from its residents, and meet at least one of the following criteria:
- Have a gross annual revenue of over $26,625,000
- Buy, receive, or sell the personal information of 100,000 or more California residents, households, or devices
- Derive 50% or more of their annual revenue from selling California residents’ personal information
CCPA compliance is mandatory for in-scope businesses. Failing to meet the regulation’s requirements can result in penalties of up to $2,663 per unintentional violation and $7,988 for each intentional violation, alongside $107–$799 per affected individual in civil damages.
On January 1, 2023, the CCPA received an update in the form of the California Privacy Rights Act (CPRA), which:
- Expanded consumer rights to include the option to correct inaccurate personal information and limit its use and disclosure
- Introduced stronger protections for sensitive personal information
- Established the California Privacy Protection Agency (CPPA) to oversee and enforce compliance
What is the General Data Protection Regulation (GDPR)?
The GDPR is a comprehensive EU law introduced in 2018 to protect the fundamental rights and freedoms of individuals within the EU and European Economic Area (EEA) when it comes to their personal information. It outlines strict requirements for how organizations collect, store, and process personal information as part of their operations.
Compliance is mandatory for any organization, regardless of its size and location, as long as it offers goods or services to, or monitors the behavior of, people in the EU/EEA. Non-compliance can lead to corrective actions and severe financial penalties of up to €10 million or 2% of the organization’s global annual revenue for lesser violations, and up to €20 million or 4% of global annual revenue for more serious infringements.
The GDPR enforces eight data subject rights to give individuals greater control over their information and hold organizations accountable for responsible data handling. They are:
- Right to be informed
- Right of access
- Right to rectification
- Right to erasure (“right to be forgotten”)
- Right to restriction of processing
- Right to data portability
- Right to object
- Rights related to automated decision-making, including profiling
In addition to these rights, the GDPR also defines seven data protection principles that inform many of the regulation’s key requirements:
{{cta_withimage14="/cta-blocks"}} | GDPR compliance checklist
What are the similarities between CCPA and the GDPR?
The primary similarity between the CCPA and the GDPR is intent. They both exist to protect data privacy and personal information of real people, not just corporate entities. The CCPA is heavily influenced by the GDPR, which explains the substantial overlap in their underlying principles, approach, and requirements.
“
Both GDPR and CCPA give individuals rights over their personal data and require transparency about what data is collected and how it’s used. They also obligate organizations to maintain formal agreements with service providers and implement reasonable security.”
Both regulations emphasize accountability and individual data rights. They grant individuals the right to access, delete, and know what personal data is collected about them. They also require organizations to fulfill individual requests related to these rights within defined time frames.
Transparency is another shared principle. Under both frameworks, organizations must provide clear privacy notices that explain how and why data is being collected and what it’s being used for.
Finally, both the GDPR and CCPA have extraterritorial reach. If your organization falls within the scope of either regulation, you must comply regardless of your location.
What are the differences between CCPA and the GDPR?
While the CCPA and the GDPR share the same overarching goal of protecting personal data, they differ in several key areas. These include:
- Scope
- Lawful bases
- Non-compliance penalties
- International transfers
1. Scope
The GDPR has a broader scope than the CCPA in terms of the organizations it covers. Under the GDPR, any organization that handles the personal data of individuals in the EU must comply with its requirements.
In contrast, the CCPA applies only to for-profit businesses that meet one of its statutory thresholds, such as minimum annual revenue or data processing volume.
While the GDPR’s protections are framed exclusively around identified or identifiable natural persons, i.e., individuals, the CCPA focuses on consumers and households. It also explicitly lists identifiers such as device IDs and IP addresses as examples of covered personal information.
2. Lawful bases
The GDPR requires organizations to establish one of six lawful bases, such as consent, contractual obligation, or legitimate interests, before processing any personal data.
The CCPA, on the other hand, requires businesses to identify their purpose for processing personal data, and also requires businesses to limit their processing to what is necessary and proportionate to those purposes, but doesn't explicitly tie those purposes to specified legal bases as a general matter.
3. Non-compliance penalties
Both the GDPR and the CCPA prescribe penalties for non-compliance, but with significant differences in severity.
The GDPR’s fines can go as high as €20 million or 4% of an organization’s global annual revenue, whichever is higher. Meanwhile, the CCPA included fines of up to $7,988 for each intentional violation, and an additional $107–$799 per affected consumer.
4. International transfers
GDPR imposes strict rules on transferring personal data outside the EU/EEA. Data can only be sent to countries that provide an adequate level of protection (an adequacy decision) or where other appropriate safeguards are in place.
In contrast, the CCPA doesn’t impose any similar requirements for international data transfers.
CCPA and GDPR: Should you comply with both?
If your organization operates in both California and the EU and interacts with data subjects in both jurisdictions, you’ll need to comply with both the GDPR and the CCPA. Otherwise, you only need to adhere to the regulation relevant to your operations.
Keep in mind that despite their similarities, alignment with one framework doesn’t automatically guarantee compliance with the other. However, if you’re already compliant with the GDPR, you may have a head start when pursuing the CCPA, and vice versa.
To streamline compliance when both regulations apply, consider the following steps:
- Build a unified data inventory to track how personal data is stored, collected, and shared
- Standardize policies and notices to maintain clarity and consistency across jurisdictions
- Automate data subject access requests (DSARs) and consumer request workflows
- Integrate privacy programs with other frameworks to reduce duplication and improve efficiency
Even with careful planning, achieving compliance with either regulation requires significant resource investments. Trying to comply with both can lead to redundancies and workflow inefficiencies. You can mitigate these issues by implementing a dedicated GDPR compliance tool to streamline your efforts and maintain consistent controls across various frameworks.
Make GDPR and CCPA compliance more efficient with Vanta
Vanta is a leading trust management platform that helps streamline compliance with more than 35 frameworks and regulations, including the CCPA, HIPAA, and SOC 2. With agentic workflows, continuous monitoring, and unified visibility, Vanta helps your team stay proactive and respond faster to potential compliance risks.
The platform’s dedicated compliance automation product comes with powerful features designed to boost productivity:
- 1,200+ automated, hourly tests
- Automated evidence collection through 400+ integrations
- Risk remediation powered by AI-generated, personalized code snippets
- Pre-built policy templates with a built-in customization tool
- End-to-end audit support
Vanta also offers an out-of-the-box GDPR compliance product that helps organizations align with the regulation efficiently by automating essential compliance workflows. It also provides step-by-step guidance that operationalizes the regulation’s complex requirements, enabling a prepared and controlled compliance journey.
Schedule a custom demo to explore compliance functionalities tailored for your team.
{{cta_simple19="/cta-blocks"}} | GDPR product page
FAQs
Which is stricter—CCPA or GDPR?
The GDPR generally includes more rigorous requirements than the CCPA. It imposes higher financial penalties for violations, requires a lawful basis for processing personal data, defines broader data subject rights, and has more comprehensive age-of-consent protections.
Does CCPA apply to businesses outside California?
Yes. The CCPA applies to for-profit businesses, regardless of their location, that collect personal information from California residents and meet some of the criteria related to revenue size and data processing volume.
Does GDPR affect US businesses?
Yes. The GDPR applies to any organization, including US businesses, that processes personal information of individuals within the EU or EEA, regardless of the organization’s location.
A note from Vanta: Vanta is not a law firm, and this article does not constitute or contain legal advice or create an attorney-client relationship. When determining your obligations and compliance with respect to relevant laws and regulations, you should consult a licensed attorney.
GDPR and other frameworks
CCPA vs GDPR: What are the differences and similarities?
Looking to streamline the work for GDPR compliance?
Data privacy has become a critical concern for both consumers and businesses. As public scrutiny increases, governments around the world have introduced legal frameworks to promote responsible use of technology, especially when it comes to collecting, storing, and selling personal data.
Two of the most prominent examples are the California Consumer Privacy Act (CCPA) and the European Union’s General Data Protection Regulation (GDPR). Both establish strict rules regarding how personal information is handled and grant individuals greater control over their data. However, they differ in several critical areas, including scope, enforcement, and compliance obligations.
In this article, we’ll discuss:
- What the CCPA is
- What the GDPR is
- The key similarities and differences between the two
- Whether your organization should comply with both regulations
What is the California Consumer Privacy Act (CCPA)?
The California Consumer Privacy Act (CCPA), enacted in 2018, is a landmark state legislation designed to enhance data privacy protections and give California consumers greater control over their personal information. It grants individuals several rights, including:
- The right to know about the personal information a business collects about them, how it’s used, and how it’s shared
- The right to delete personal information collected about them (with some exceptions)
- The right to opt out of the sale of personal information
- The right to non-discrimination for exercising their CCPA rights
Under the CCPA, personal information is broadly defined as any data that identifies, relates to, or could be reasonably linked to an individual or household in California. This includes names or nicknames, email addresses, IP addresses, purchase histories, and sensitive personal information.
The CCPA applies to all for-profit businesses that operate within California, collect data from its residents, and meet at least one of the following criteria:
- Have a gross annual revenue of over $26,625,000
- Buy, receive, or sell the personal information of 100,000 or more California residents, households, or devices
- Derive 50% or more of their annual revenue from selling California residents’ personal information
CCPA compliance is mandatory for in-scope businesses. Failing to meet the regulation’s requirements can result in penalties of up to $2,663 per unintentional violation and $7,988 for each intentional violation, alongside $107–$799 per affected individual in civil damages.
On January 1, 2023, the CCPA received an update in the form of the California Privacy Rights Act (CPRA), which:
- Expanded consumer rights to include the option to correct inaccurate personal information and limit its use and disclosure
- Introduced stronger protections for sensitive personal information
- Established the California Privacy Protection Agency (CPPA) to oversee and enforce compliance
What is the General Data Protection Regulation (GDPR)?
The GDPR is a comprehensive EU law introduced in 2018 to protect the fundamental rights and freedoms of individuals within the EU and European Economic Area (EEA) when it comes to their personal information. It outlines strict requirements for how organizations collect, store, and process personal information as part of their operations.
Compliance is mandatory for any organization, regardless of its size and location, as long as it offers goods or services to, or monitors the behavior of, people in the EU/EEA. Non-compliance can lead to corrective actions and severe financial penalties of up to €10 million or 2% of the organization’s global annual revenue for lesser violations, and up to €20 million or 4% of global annual revenue for more serious infringements.
The GDPR enforces eight data subject rights to give individuals greater control over their information and hold organizations accountable for responsible data handling. They are:
- Right to be informed
- Right of access
- Right to rectification
- Right to erasure (“right to be forgotten”)
- Right to restriction of processing
- Right to data portability
- Right to object
- Rights related to automated decision-making, including profiling
In addition to these rights, the GDPR also defines seven data protection principles that inform many of the regulation’s key requirements:
{{cta_withimage14="/cta-blocks"}} | GDPR compliance checklist
What are the similarities between CCPA and the GDPR?
The primary similarity between the CCPA and the GDPR is intent. They both exist to protect data privacy and personal information of real people, not just corporate entities. The CCPA is heavily influenced by the GDPR, which explains the substantial overlap in their underlying principles, approach, and requirements.
“
Both GDPR and CCPA give individuals rights over their personal data and require transparency about what data is collected and how it’s used. They also obligate organizations to maintain formal agreements with service providers and implement reasonable security.”
Both regulations emphasize accountability and individual data rights. They grant individuals the right to access, delete, and know what personal data is collected about them. They also require organizations to fulfill individual requests related to these rights within defined time frames.
Transparency is another shared principle. Under both frameworks, organizations must provide clear privacy notices that explain how and why data is being collected and what it’s being used for.
Finally, both the GDPR and CCPA have extraterritorial reach. If your organization falls within the scope of either regulation, you must comply regardless of your location.
What are the differences between CCPA and the GDPR?
While the CCPA and the GDPR share the same overarching goal of protecting personal data, they differ in several key areas. These include:
- Scope
- Lawful bases
- Non-compliance penalties
- International transfers
1. Scope
The GDPR has a broader scope than the CCPA in terms of the organizations it covers. Under the GDPR, any organization that handles the personal data of individuals in the EU must comply with its requirements.
In contrast, the CCPA applies only to for-profit businesses that meet one of its statutory thresholds, such as minimum annual revenue or data processing volume.
While the GDPR’s protections are framed exclusively around identified or identifiable natural persons, i.e., individuals, the CCPA focuses on consumers and households. It also explicitly lists identifiers such as device IDs and IP addresses as examples of covered personal information.
2. Lawful bases
The GDPR requires organizations to establish one of six lawful bases, such as consent, contractual obligation, or legitimate interests, before processing any personal data.
The CCPA, on the other hand, requires businesses to identify their purpose for processing personal data, and also requires businesses to limit their processing to what is necessary and proportionate to those purposes, but doesn't explicitly tie those purposes to specified legal bases as a general matter.
3. Non-compliance penalties
Both the GDPR and the CCPA prescribe penalties for non-compliance, but with significant differences in severity.
The GDPR’s fines can go as high as €20 million or 4% of an organization’s global annual revenue, whichever is higher. Meanwhile, the CCPA included fines of up to $7,988 for each intentional violation, and an additional $107–$799 per affected consumer.
4. International transfers
GDPR imposes strict rules on transferring personal data outside the EU/EEA. Data can only be sent to countries that provide an adequate level of protection (an adequacy decision) or where other appropriate safeguards are in place.
In contrast, the CCPA doesn’t impose any similar requirements for international data transfers.
CCPA and GDPR: Should you comply with both?
If your organization operates in both California and the EU and interacts with data subjects in both jurisdictions, you’ll need to comply with both the GDPR and the CCPA. Otherwise, you only need to adhere to the regulation relevant to your operations.
Keep in mind that despite their similarities, alignment with one framework doesn’t automatically guarantee compliance with the other. However, if you’re already compliant with the GDPR, you may have a head start when pursuing the CCPA, and vice versa.
To streamline compliance when both regulations apply, consider the following steps:
- Build a unified data inventory to track how personal data is stored, collected, and shared
- Standardize policies and notices to maintain clarity and consistency across jurisdictions
- Automate data subject access requests (DSARs) and consumer request workflows
- Integrate privacy programs with other frameworks to reduce duplication and improve efficiency
Even with careful planning, achieving compliance with either regulation requires significant resource investments. Trying to comply with both can lead to redundancies and workflow inefficiencies. You can mitigate these issues by implementing a dedicated GDPR compliance tool to streamline your efforts and maintain consistent controls across various frameworks.
Make GDPR and CCPA compliance more efficient with Vanta
Vanta is a leading trust management platform that helps streamline compliance with more than 35 frameworks and regulations, including the CCPA, HIPAA, and SOC 2. With agentic workflows, continuous monitoring, and unified visibility, Vanta helps your team stay proactive and respond faster to potential compliance risks.
The platform’s dedicated compliance automation product comes with powerful features designed to boost productivity:
- 1,200+ automated, hourly tests
- Automated evidence collection through 400+ integrations
- Risk remediation powered by AI-generated, personalized code snippets
- Pre-built policy templates with a built-in customization tool
- End-to-end audit support
Vanta also offers an out-of-the-box GDPR compliance product that helps organizations align with the regulation efficiently by automating essential compliance workflows. It also provides step-by-step guidance that operationalizes the regulation’s complex requirements, enabling a prepared and controlled compliance journey.
Schedule a custom demo to explore compliance functionalities tailored for your team.
{{cta_simple19="/cta-blocks"}} | GDPR product page
FAQs
Which is stricter—CCPA or GDPR?
The GDPR generally includes more rigorous requirements than the CCPA. It imposes higher financial penalties for violations, requires a lawful basis for processing personal data, defines broader data subject rights, and has more comprehensive age-of-consent protections.
Does CCPA apply to businesses outside California?
Yes. The CCPA applies to for-profit businesses, regardless of their location, that collect personal information from California residents and meet some of the criteria related to revenue size and data processing volume.
Does GDPR affect US businesses?
Yes. The GDPR applies to any organization, including US businesses, that processes personal information of individuals within the EU or EEA, regardless of the organization’s location.
A note from Vanta: Vanta is not a law firm, and this article does not constitute or contain legal advice or create an attorney-client relationship. When determining your obligations and compliance with respect to relevant laws and regulations, you should consult a licensed attorney.
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